Doctrine of merger distinguishes refusal of special leave from appellate adjudication, preserving review and remanded proceedings where appropriate.

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....Doctrine of merger under Article 136 depends on whether the Supreme Court granted leave and exercised appellate jurisdiction, not merely on disposal of a special leave petition. A non-speaking refusal of leave neither merges the challenged order nor confirms its reasoning, creates automatic res judicata, or independently bars review or writ proceedings. A speaking refusal likewise does not cause merger, although legal propositions expressly declared may bind under Article 141. Merger follows when leave is granted and the appeal is decided. In remanded GST proceedings, an earlier dismissal of special leave therefore does not prevent consideration of residual grounds or reliance on a later binding ruling, subject to applicable review, limitation, and procedural requirements.....